On September 28, 2026, the Council of the European Union adopted Council Decision (CFSP) 2026/2185, published the same day in the Official Journal of the European Union (OJ L 2026/2185). The Decision amends Council Decision 2014/145/CFSP and entered into force on that publication date. Recital 4 adds 10 persons and 17 entities, citing the unlawful deportation and forcible transfer of Ukrainian children, their forced adoption and re-education.
EU banks and credit institutions, EU payment service providers and e-money institutions, EU investment firms and financial intermediaries, EU crypto-asset service providers, and EU insurance and reinsurance undertakings must immediately update sanctions screening lists to include the 10 persons and 17 entities designated by Council Decision (CFSP) 2026/2185, screen ongoing customer relationships and transactions, and freeze any funds or economic resources of the listed persons and entities, so that no funds or economic resources are made available to them, directly or indirectly. Failure to freeze those assets, or to comply with the EU asset-freeze obligations that follow from a listing under Decision 2014/145/CFSP, exposes obliged entities to national penalties for sanctions breaches, including substantial fines and criminal liability under Member State sanctions enforcement laws.
What did Decision (CFSP) 2026/2185 add on September 28, 2026?
Article 1 amends the Annex to Decision 2014/145/CFSP by adding the persons and entities in the Annex to Decision (CFSP) 2026/2185. Article 2 puts the Decision into force on Official Journal publication, September 28, 2026, which is also the listing date printed on the new entries (28.9.2026). The Official Journal text available in the pack names four of the ten persons. The other six persons and all 17 entities sit in that Annex and have to be loaded from the published Decision, not from a partial extract. The four named persons are:
| Annex no. | Name | Function stated in the Annex | Date of listing |
|---|---|---|---|
| 2111 | Oleg Ivanovich Sladkevich | Director of Horlivka School No 42, so-called Donetsk People's Republic | September 28, 2026 |
| 2112 | Rustam Nurgaliyevich Minnikhanov | President of the Republic of Tatarstan | September 28, 2026 |
| 2113 | Aleksandr Mikhailovich Kalyagin | Minister of Education and Science of Zaporizhzhia Oblast under the occupation administration | September 28, 2026 |
| 2114 | Oleg Vladimirovich Trofimov | Acting Minister of Education and Science of the so-called Donetsk People's Republic | September 28, 2026 |
The Annex reasons are screening facts. Sladkevich is listed for forced assimilation, including indoctrination, of Ukrainian minors. Minnikhanov is listed for facilitating deportation of Ukrainian children to camps in Tatarstan, including the Miras camp in Zelenodolsky district. Kalyagin is listed for patriotic and militarised education of Ukrainian minors. Trofimov is listed for coordinating indoctrination and militarised education in the so-called Donetsk People's Republic. Dates of birth, tax numbers and, for Kalyagin, a passport number and SNILS belong in the screening record with the Latin-script name.
Who is exposed, and what must they freeze?
Exposure follows the EU market: banks and credit institutions, payment service providers and e-money institutions, investment firms and financial intermediaries, crypto-asset service providers, and insurance and reinsurance undertakings that screen the Ukraine territorial-integrity list. A payment, a custody account, an insurance contract or a crypto transfer that touches a listed person or entity is in scope wherever the relationship sits inside the Union.
Addition to the Annex of Decision 2014/145/CFSP brings the person or entity under that Decision's asset freeze, the prohibition on making funds or economic resources available, directly or indirectly, and the travel restrictions already attached to listed persons. Decision (CFSP) 2026/2185 extends that list. It does not open a new programme. A list frozen before September 28, 2026 misses these 27 designations.
What must screening teams do immediately?
- Load all 10 persons and 17 entities from the Annex of Decision (CFSP) 2026/2185 into the sanctions screening list, including Cyrillic names, aliases and the identifiers the Annex prints (date of birth, tax identification number, passport, SNILS).
- Re-screen ongoing customer relationships, counterparties, beneficial owners, payment beneficiaries and insurance policyholders against the updated list.
- Freeze any funds or economic resources of a confirmed match and block any new availability of funds or economic resources, directly or indirectly.
- Keep the file that shows the list was updated on the publication date, because national enforcement looks at whether the freeze followed the entry into force.
Continuous, per-jurisdiction monitoring is what surfaces an Official Journal listing of this kind the moment it publishes, before the next batch screening cycle.
What happens if a listed person's assets are not frozen?
Decision (CFSP) 2026/2185 sets no euro amount. Penalties sit in Member State law that enforces EU restrictive measures. Failure to freeze listed assets, or to comply with the asset-freeze obligations, exposes the obliged entity to those national penalties, including substantial fines and criminal liability. Examples are the French Code monétaire et financier, the German AWG and AWV, and Italian Law 234/2012. The travel restriction on a natural person does not replace the asset freeze, which covers funds and economic resources held on the listing date and any new making available.
Next, pull the full Annex from the Official Journal text, confirm every one of the 10 persons and 17 entities is on the live screening list, re-run relationship and transaction screening, freeze confirmed matches, and brief sanctions, financial-crime and legal teams on the September 28, 2026 entry into force. Obsidian tracks this class of Official Journal amendment as it is published, jurisdiction by jurisdiction.
